California, United States of America
The following excerpt is from Krieger v. Nick Alexander Imports, Inc., 234 Cal.App.3d 205, 285 Cal.Rptr. 717 (Cal. App. 1991):
In Frazier v. Metropolitan Life Ins. Co. (1985) 169 Cal.App.3d 90, 214 Cal.Rptr. 883, the court determined that an action for breach of the covenant of good faith and fair dealing was controlled by the four-year limitations period of Code of Civil Procedure section 337, subdivision 1 for an action arising on written contract. The respondent had urged the court to apply the one year limitations period of Code of Civil Procedure section 340, subdivisions (1) and (3), governing actions for personal injury and punitive damages claims, or Code of Civil Procedure section 339, SUBDIVISION[234 Cal.App.3d 221] 1, which governs actions upon a contract not founded on a written instrument.
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